On June 10, 2015, six federal agencies, including the Consumer Financial Protection Bureau (CFPB) issued Joint Standards for Assessing the Diversity Policies and Practices of Entities Regulated by the Agencies (Joint Standards). Collectively, the agencies support the goal of Section 342 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank) to promote transparency and awareness of diversity policies and practices and encourage sharing standards to promote to the regulated businesses.

Section 342 lacks any formal enforcement mechanism and must rely on voluntary self-assessment and disclosure to CFPB a voluntary display of diversity information on the company websites. Notably, the CFPB may not utilize the disclosure or non-disclosure of Diversity & Inclusion plan under examination and supervisory authority.

This guide sets forth a framework for regulated entities to use in creating a new diversity and inclusion program. Alternatively, this guide may be used to alter a diversity and inclusion program already in place. Ideally, regulated entities will establish a diversity and inclusion program based on the Joint Standards and incorporate the program with other diversity related requirements such as those listed above.

Developed by:

Anthony M. Sharett, Former Partner at BakerHostetler, LLP

Keesha N. Warmsby, Associate, Baker Hostetler, LLP

Kristin Messerli, President and Founder, Cultural Outreach Solutions

Chapters include:

Definitions

Joint Standards in Depth

Use of Information by Agencies

Enforcement

Self-Assessment

Publication of a Diversity and Inclusion Strategic Plan

Model Policies and Procedures

Organizational Commitment to Diversity

Hiring and Retention

Supplier Diversity and Procurement Business Practices

Practices to Promote Transparency of Organizational Diversity and Inclusion